MACRA Minute November 2020

Preliminary 2019 QPP Participation Data

In late October, Centers for Medicare & Medicaid Services (CMS) released a blog post and infographic to share preliminary participation data for the Quality Payment Program (QPP) in 2019.

Key findings include the following:

  • 97.44% of MIPS eligible clinicians engaged in QPP.
  • Overall, MIPS engagement rose from 871,838 clinicians in 2018 to 930,219 clinicians in 2019.
  • MIPS APM participation rose from 356,546 clinicians in 2018 to 416,281 clinicians in 2019.
  • 6.83% of MIPS eligible clinicians received reweighting of one or more MIPS performance categories (correction).
  • The number of Qualifying Advanced Payment Model Participants (QPs) rose from 183,306 clinicians in 2018 to 195,564 in 2019.

For more data please review the 2019 QPP Participation Results Infographic

Telligen Performers of Excellence Program

The Telligen Quality Payment Program Support Center is pleased to sponsor the Telligen QPP-SURS Performers of Excellence Award.

The Performers of Excellence Award will formally recognize physician practices that demonstrate excellence in quality improvement and are actively participating in the Centers for Medicare and Medicaid Services (CMS) Quality Payment Program (QPP).

To be eligible for the Performers of Excellence Award, practices must have 15 or fewer clinicians and be located in Iowa, Nebraska, North Dakota, or South Dakota. Award criteria includes quality improvement strategies that align with the four performance categories of the QPP: Quality, Promoting Interoperability, Improvement Activities, and Cost. Practices must also participate in Telligen’s QPP Connect Live! call-in sessions and other QPP- related webinars. You can learn more about the specifics of the program by watching our informational webinar posted here. We will continue to share more information about the program in the coming months.

  • Reminder: Application for the 2020 Promoting Interoperability Hardship and Extreme and Uncontrollable Circumstances Exception are due December 31st at 8:00 p.m. ET.

Who is Eligible for a MIPS Promoting Interoperability Hardship Exception? MIPS-eligible clinicians, groups, and virtual groups may qualify for a re-weighting of the Promoting Interoperability performance category to 0% if they:

  • Are a small practice;
  • Have decertified EHR technology;
  • Have insufficient internet connectivity;
  • Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress, or vendor issues; or
  • Lack control over the availability of CEHRT.

Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?  MIPS-eligible clinicians, groups, and virtual groups may qualify for a re-weighting of any or all MIPS performance categories to 0% if they are affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must render them unable to:

  • Collect information necessary to submit for a performance category; or
  • Submit information that would be used to score a performance category for an extended period of time.

Additionally, these circumstances must impact their normal processes, affecting performance on cost measures and other administrative claims measures.

COVID-19 Flexibilities: The COVID-19 pandemic has impacted all clinicians across the United States and territories. However, CMS recognizes that not all practices have been impacted by COVID-19 to the same extent. For the 2020 performance year, CMS will be using the Extreme and Uncontrollable Circumstances policy to allow MIPS-eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency. For more information, visit the QPP COVID-19 Response webpage.

How Do Practices Apply? New for 2020: Practices must have a HCQIS Access Roles and Profile (HARP) account to complete and submit an exception application. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

How Do Practices Know If They Are Approved? If a practice submits an application for either of the exceptions, they will be notified by email if their request was approved or denied. If approved, this will also be added to their eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

Increasing QP Thresholds

Qualifying Alternative Payment Model (APM) Participant (QP) thresholds are increasing beginning on January 1, 2021. If any of your clinicians were a QP for the 2020 performance year, they may not necessarily receive QP status for the 2021 performance year. Depending on their status in 2021, they may be required to participate in MIPS even if they haven’t in previous years.

What are the Thresholds for 2021?

For QP status:

  • The payment amount threshold is increasing from 50% in 2020 to 75% in 2021.
  • The patient count threshold is increasing from 35% in 2020 to 50% in 2021.

For Partial QP status:

  • The payment amount threshold is increasing from 40% in 2020 to 50% in 2021.
  • The patient count threshold is increasing from 25% in 2020 to 35% in 2021.

If any of your clinicians qualify as a Partial QP, they will be able to choose whether or not they want to participate in MIPS but will not be eligible for the 5% incentive payment.

How do I know if I am a QP in 2021?

CMS will use three snapshot dates—March 31, June 30, and August 31, 2021, to review data to make QP determinations. CMS will make determinations approximately 4 months after the end of each snapshot date, at which point you will be able to check the Quality Payment Program Participation Status Tool for updates to APM status.

CMS LAN Webinar

The next CMS LAN Webinar will be held in December, Implications of the Year 5 Final Rule for Solo and Small Group. Use the links below to register for the time that works best for you.

              Tuesday December 8th 2:30-3:30pm CT

              Thursday December 10th 10-11am CT

Telligen Webinars

2020 MIPS Hardship Exceptions

This webinar provides detailed information on 2020 Hardship Exceptions for both Promoting Interoperability and Extreme and Uncontrollable Circumstances. It includes details on when each application is applicable and the steps to fill out an application.

Watch the recording or download the slides here.

Telligen QPP SURS Performers of Excellence Award Program

Announcement and details of Telligen’s new QPP SURS Performers of Excellence award program for the 2021 MIPS performance year. Watch the recording or download the slides here.

New Resources in the QPP Resource Library

The following resources were updated or added in October

2020 MIPS Scoring Guide

2020 30-Day All-Cause Hospital Readmission Measure

2020 MIPS Exception Application Fact Sheet

2020 MIPS Automatic Extreme and Uncontrollable Circumstances Policy

2018 QPP Experience Report

2019 QPP Participation Results Infographic

2020 MIPS Quality User Guide

2020 MIPS 1010 Guide

QPP Access User Guide

2020 MIPS Quality User Guide

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